Notes from session with Norm Suchar, Director, Office of Special Needs Assistance Programs (SNAP) at the Council of State Community Development Agencies (COSCDA) Program Managers Training Conference on March 14, 2017.
CoC NOFA Timeline
· Registration Notice will be released in about 3 weeks or so.
· Grant Inventory Worksheet should be out in early April. This year the GIW should be significantly shorter and easier to use.
· NOFA will be released in May. Depending on whether or not Congress has passed a full-year appropriations for HUD, some elements may be missing (such as tiers). They will send out revised NOFA once 2017 funding is finalized.
· NOFA will be due at the end of August.
· Decisions will be announced in December.
· Goal is to get grant agreements out by late January.
HUD Reimagining Process
The SNAPs office has been looking at every component of the CoC NOFA process and is breaking things down into their component parts looking for ways to improve and streamline the process. For instance, this year there will be fewer CoC application questions. Each year they hope to make the process more efficient.
HUD understands that the PIT process is not perfect. They realize that weather has a significant impact. However, they look at PIT counts over time and believe that over the course of time the process will even out any blips in a given year. While they are considering PIT counts at other times of the year, there are no immediate plans to move the PIT Count from January.
Feedback to CoCs
The SNAPs office is trying to provide more feedback to CoCs on their scores. This year they held three (3) regional briefing calls. Each CoC also received a three-page document covering the 15 highest priority questions. CoCs will really low scores received a phone call from HUD with some more in-depth feedback. HUD has to balance providing useful feedback with avoiding giving CoCs the answers to the questions. Plus, questions change each year as tweaks are made.
Notices and Rules
· Notice that PHAs can be subrecipients for ESG grants should be released soon.
· A utility notice will also be released soon. This is to assist with accounting for the cost of utilities when it is not included in the rent.
· A notice for further comment on CoC rules will be released at some point, asking CoCs to provide comment on specific sections of the CoC rules. Not timeline for the release, but it is upcoming. Norm urged CoCs to take the time to respond as HUD cannot make changes to Rules unless there is an associated comment.
· HMIS final rule is also being worked on. Again, no timeline but it will go into significant detail on HMIS requirements.
· The final ESG rules are "further behind" but are being drafted. Since the interim rules are currently working without too many issues, this is a lower priority.
· Norm wanted to draw attention to two recent rules: The Mobility Rule change (allowing CoCs to pay rent outside of the CoC geographic area) and the Coordinated Entry (CE) rule released in January. Tools and technical assistance on the CE rule are in the works.
Equal Access Rule
Norm briefly touched on the Equal Access rule updated in 2016 requiring that all facilities take clients based on the self-disclosed gender identity. There are no exemptions for DV shelters. Norm indicated that they worked with national DV leaders in crafting this rule. He also said there are a lot of imagined problems but very few actual issues that have arisen over this rule.
System Performance Measures
HUD continues to increasingly focus on system performance in scoring the CoC applications. It is critically important for CoCs to focus on those who have been homeless the longest. 2016 was the first year that CoCs submitted system performance measures and it generated some interesting results. The average length of homelessness for Emergency Shelter, Safe Havens, and Transitional Housing was 109 days. Most values made sense, but one CoC indicated the longest length of stay was 35,182 days (or over 96 years). The shortest length of stay was -1 days (this is impossible to generate in the system so someone had to enter this negative number). Both numbers are clearly wrong. Data quality needs to improve. The system will now reject numbers that are too outside an expected range.
One important piece of information was the return to homelessness number. The national average was an 8% return to homelessness within 0-6 months. Four (4) percent returned to homelessness in 6-12 months, and another 4% returned during the 12-24 month period. Overall, during the 24 month period there was a 16% return to homelessness.
Norm said that this seems to indicate that the 0-6 month period after someone exits to permanent housing is a critical time to avoid the client falling back into homelessness. Support services and interventions are key.
With respect to the overall system performance tracking, he did indicate there still remain significant data quality issues. They will be issuing some tools in the next 6-12 months that will help CoCs analyze their data and hopefully improve it.
The importance of system performance data in scoring the CoC application will be ramping up over time. Right now the "stakes are low" but as data quality improves it will be increasingly impactful on your scores.
The two biggest data quality issues he sees are too many "exits to unknown" and not enough data to de-duplicate numbers.
A question was asked about recovery housing and if there is any additional guidance from HUD. Norm said that some recovery housing models are performing well while others are not. HUD is not a substance abuse agency so it is difficult for them to really provide best practices and additional guidance. However, for a recovery housing model to be successful they must be exiting clients to permanent housing at high rates. "Research shows you are wasting your time if you are exiting a resident to homelessness."
Uniform Funding Agencies
Norm indicated there are now five (5) approved Uniform Funding Agencies (UFAs). They would like to see more. About 10 or 15 apply each year but few are approved. To be a UFA, you must meet all requirements. You can't meet 80% or 90%, but 100% of the requirements in 24 CFR 528.11 to be approved as a UFA. HUD is working on developing a self-assessment for CoCs to determine if they are ready for a UFA.